Mark Fowler and Joylyn Souter-Fowler - Page 2

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          petitioner’s 1990-92 tax liabilities.  In that same notice                  
          respondent also rejected petitioner’s offer in compromise.  On              
          that same date respondent sent Mark Fowler and Joylyn Souter-               
          Fowler (petitioners) a second Notice of Determination Concerning            
          Collection Action(s) Under Section 6320 and/or 6330.  In this               
          notice respondent sustained the filing of a Federal tax lien with           
          respect to petitioners’ 1994-96 tax liabilities, and respondent             
          again rejected petitioners’ offer in compromise.                            
               Prior to these determinations, petitioners sought and were             
          offered an Appeals hearing, but they did not attend due to                  
          personal reasons.  One month after the scheduled hearing date,              
          the Appeals officer issued the above determinations sustaining              
          the filing of the Federal tax liens and rejecting petitioners’              
          offers in compromise.  With respect to both determinations,                 
          petitioners appealed to this Court.                                         
               The issue for consideration is whether respondent abused his           
          discretion by rejecting petitioners’ offers in compromise and by            
          sustaining the filing of the Federal tax liens.                             

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Last modified: May 25, 2011